## DRAFT Information Collection Request Supporting Statement for the

PM 2.5 

## Nation al Ambient Air Quality Standards

State Implementation Plan Requirements Rule

EPA ICR Number 2258. 0 3

OMB Control No. 2060

- 0611

Prepared by:

Office of Air Quality Planni ng and Standards

Office of Air and Radiation U.S. Environmental Protection Agency Research Triangle Park, North Carolina 27711

March 2 3 , 20152



### EPA Information Collection Request Renewal for the

PM 2.5 

### National Ambient Air Quality Standard s Sta te Implementation Plan Requirements Rule



## Table of Contents

1. Identification of the Information Collection Request...

............... ......page 3

2. Need for and Use of the Collection..........................................page 4

3. Non

- Duplication, Consultation, and other Collection C riteria......... page 6

4. Respondents and the Inform ation Requested..............................page 9

5. Information Collected

— Agency Activities, Collection Methodology and Information Management.....................................................page 1 2

6. Estimating the Burden and Cost of the Collection.................. ......page 143



### 1. Identification of the Information Collection Request

1(a) Title of the Information Collection

The title of the Information Collection Request is PM 2.5 National Ambient Air Quality

Standard s (NAAQS) State Implementation Plan Requi rements (SIP) Rule , ICR number 2258. 0 3

, and OMB Control Number 2060

- 0611, expiration date: May 1, 201 8

.

1(b) Abstract/Executive Summary

The EPA has established a suite of PM 2.5 standards based on evidence and numerous health studies demonstrating that s erious health effects are associated with exposures to elevated levels

of PM 2.5

. Estimates show that attainment of the PM 2.5 standards would result in tens of thousands fewer premature deaths each year, tens of thousands fewer hospital admissions each year , and hundreds of thousands fewer doctor visits, absences from work and school, and respiratory illnesses in children annually . EPA initially established annual and 24

- hour PM 2.5 standards in

1997. The 24

- hour standard was subsequently revised in 2006, and the annual standard was

revised in 2012.

The EPA is proposing th e PM 2.5 NAAQS S IP Requirements Rule to describe the CAA requirements that must be met by states with nonattainment areas required to develop attainment plans for attaining and maintaining th e NAAQS. The intended effect of the SIP Requirements

Rule is to provide certainty to states regarding their planning obligations such that states may begin SIP development. Only states with nonattainment areas are required to submit SIPs that meet the requ irements of the rule.

The information collection activities in this proposed rule have been submitted for approval

to the O ffice of Management and Budget (O MB ) under the Paperwork Reduction Act (PRA).

The P RA requires the EPA to assess the administrativ e burden (in hours and dollars) for state air agencies to develop plans to attain the PM 2.5 NAAQS, and for EPA to review and take action on such plans.

The EPA estimates the additional administrative burden for states with nonattainment areas

for the 2012 PM 2.5 NAAQS to be 1 26 ,000 hours , and the estimated administrative burden for

EPA to be 1 3,860 hours . With respect to ongoing implementation of the 1997 and 2006 PM 2.5 standards, the EPA estimates the total additional administrative burden for states t o be 1 45,800

hours , and the estimated administrative burden for EPA to be 16

, 038 hours . In this analysis, f ifty percent of the hours are assumed to be expended in the first year
, with the remain ing hours evenly divided between the second and third years of the ICR period

.

For the newly designated nonattainment area burden, the present value of the total additional

costs for state governments, the respondents, estimated at $ 7.6 million for the 3 year period

. On an equivalent annual basis that is $ 2.5 milli on per year during the 3 year period of the ICR . For the remaining 1997 and 2006 PM25 nonattainment burden, the present value of the total4

additional costs for state governments, the respondents, estimated at $ 8.8 million for the 3 year period

. On an equi valent annual basis that is $ 2.9 million per year during the 3 year period of the

ICR . Therefore, t he present value of the total additional costs for state governments, the states having to respond with SIP revision , estimated at $ 16.4 million for the 3 year period

. On an equivalent annual basis that is $ 5.4 million per year during the 3 year period of the ICR

.

For the newly designated nonattainment area burden, t he present value of the Agency administrative cost burden is estimated at $ 0

. 8 million do llars for the 3 year period

. This is equivalent to equal annual basis of $ 0

. 3 million per year during the three year period. For the remaining 1997 and 2006 PM25 nonattainment burden, t he present value of the Agency

administrative cost burden is estimated at $ 1

. 0 million dollars for the 3 year period

. This is equivalent to equal annual basis of $ 0

. 3 million per year during the three year period. Therefore,

t he present value of the Agency administrative cost burden is estimated at $ 1.8 million dollars

for the 3 year period

. This is equivalent to equal annual basis of $ 0

. 6 million per year during the three year period.

The incremental administrative burden for the areas and activities covered by this ICR is mitigated by the fact that many states may be able to attain the standards based on existing federal and state emission reduction programs and may not need substantial additional emissions reductions from new state regulations. In addition, the fourteen areas designated in December 2014 as not attaining t he 2012 PM 2.5 NAAQS are located in 6 states, all of which previously had areas designated as nonattainment for the 1997 or 2006 PM 2.5 NAAQS. Thus, these states all have experience with developing state implementation plans for attaining previously establis hed

PM 2.5 NAAQS.



### 2. Need For and Use of the Collection
2(a) Need/Authority for the Collection

The Clean Air Act, which was last amended in 1990, requires the EPA to establish National Ambient Air Quality Standards (NAAQS) for air pollutants that may reas onably be anticipated to endanger public health or welfare, and which result from numerous or diverse sources. On July 18, 1997, the EPA revised the NAAQS for particulate matter to add new standards for fine partic ulate matter ( particles of solid and liqui d material less than 2.5 microns in aerodynamic

diameter ) , using PM 2.5 as the indicator . The EPA established health

- based (primary) annual and

24

- hour standards for PM 2.5 (62 FR 38652)

. The annual standard was set a level of 15 micrograms per cubic meter, based on the 3

- year average of annual mean PM 2.5 concentrations

. The 24

- hour standard was set a level of 65 micrograms per cubic meter, based on the 3

- year average of the 98 th percentile of 24

- hour concentrations. The welfare

- based secondary standards

were established identical to the primary standards.

The initial PM 2.5 National Ambient Air Quality Standard Implementation rule was proposed November 1, 2005 (70 FR 65983) and was promulgated on April 25, 2007 (72 FR 20586). The preamble to the proposed and final regulation addresses the administrative burden in general terms. The preamble to the final rule stated that an ICR would be prepared. The first ICR (No. 2258.01) covered a period from April 5, 2008 through April 4, 2011.5

On October 17, 2006, the EP A revised the NAAQS for fine particles. The EPA established a new primary 24

- hour standards for PM 2.5 (71 FR 61144). The 24

- hour standard was set a level of 35 micrograms per cubic meter, based on the 3

- year average of the 98 th percentile of 24

- hour

concen trations. The annual standard remained unchanged at a level of 15 micrograms per cubic meter, based on the 3

- year average of annual mean PM 2.5 concentrations. The time period covered in the second ICR (2258.02) was a three year per iod from June 1, 2011 thr ough May 31,

2014.

On December 14 , 2012, the EPA revised the NAAQS for fine particles. The EPA established a new primary annual standard PM 2.5 (78 FR 3086). The annual standard was set at a level of 12 micrograms per cubic meter, based on the 3

- year avera ge of annual mean PM 2.5 concentrations

. The 24

- hour standard remained unchanged at a level of 3 5 micrograms per cubic meter, based on

the 3

- year average of the 98 th percentile of 24

- hour concentrations. The time period covered in the third ICR (2258.03) is anticipated to be a three year period from May 1, 201 5 through May 31, 201 8

.

Part D of Title I of the Clean Air Act sets forth the implementation plan requirements for areas designated nonattainment for a National Ambient Air Quality Standard

. T his rule provides

the framework for state s to follow in develop ing SIPs to a ttain the 2012 PM2.5 NAAQS and any

future revisions to the PM 2.5 NAAQS. The rule also applies to the remaining nonattainment areas

for the 1997 PM 2.5 NAAQS and the 2006 PM 2.5 NAAQS.

This framework reflects the applicable requirements de scribed in the CAA part D nonattainment area provisions found in sections 172 (subpart 1) and sections 188

- 190 (subpart 4). A PM 2.5 SIP must include rules requiring emission reductions and a demonstration sh owing whether the particular area can attain the standard by its attainment date. A s tate plan submittal for attaining the PM 2.5 NAAQS is due to EPA within 18 months after the date the area is designated as nonattainment. After a state submits a SIP, the C AA requires the EPA to review the plan

, and approve or disapprove it

.

2( b ) User/Users of the Data

The data collected from the state or local air agency respondents will include the

nonattainment SIP elements required by the CAA and describe d in more det ail in the PM 2.5 SIP requirements rule. The PM 2.5 SIP must contain state rules and other requirements designed to achieve the NAAQS by the deadlines established under the CAA

.

The PM 2.5 SIP submitted by the state must include t he various requirements in subpart 1 and subpart 4 , including:

 Baseline emission inventory and projection year inventory for stationary, mobile, and

area emissions sources in the nonattainment area consistent with section 51.1008 of the

rule.

 For Moderate areas, a n analysis of econ omic and technological feasibility of potential control measures (i.e., reasonably available control measures ( RACM ) and reasonably available control technology ( RACT ) ), and the adoption of state rules requiring emission6

reductions to ensure attainment of the standard “as expeditiously as practicable ,”

consistent with sections 51.1007 and 51.1009 of the rule.

 For Serious areas, an analysis of economic and technological feasibility of potential control measures (i.e., best available control measures (B ACM ) a nd best available control technology (B ACT )), and the adoption of state rules requiring emission reductions to ensure attainment of the standard “as expeditiously as practicable,” consistent with

sections 51.10 10 of the rule.

 A proposed attainment date con sistent with section 51.1004 of the rule.

 An attainment demonstration with air quality modeling showing that existing federal and state emission reduction programs, plus any new emission reduction programs adopted by the state, will result in expeditious attainment by the attainment date , consistent with

section 51.1011 of the rule . The attainment demonstration must meet the requirements of 40 CFR 51.112 and Part 51, Appendix W

, and must include emission inventory data, modeling results, and emission reduc tion analyses on which the state has based its projected attainment date

. The attainment demonstration and supporting air quality modeling should be consistent with the EPA ’s PM 2.5 modeling guidance

 A plan showing that future emission reductions will provi de for reasonable further progress ( RFP ) toward attainment of the standard for the period prior to the area ’ s attainment date , consistent with section 51.1012 of the rule; and annual reporting on quantitative milestones showing progress in the implementati on of the attainment plan and associated control measures, consistent with section 51.1013 of the rule.

The s tate s use this information and analysis to fulfill federal obligations under Title I, Subpart D of the Clean Air Act and the PM 2.5 Implementation Rule. They also use the attainment demonstrations, RFP, RACT and RACM determinations to inform their citizenry, including potentially regulated entities

. The potentially regulated entities use this information in assessing future emission reduction requir ements.

The EPA regional and headquarters offices will use the submitted information in determining the adequacy of the various elements of the PM 2.5 implementation plan. After a state submits a

SIP with the appropriate technical supporting documentation

, the EPA is required under the

CAA to approve or disapprove the SIP within 12 months. Emission reduction regulations developed by the states become federally enforceable when approved by the EPA.



### 3. Non

- Duplication, Consultations, and Other Collection Crit eria

3(a) Non

- Duplication

As noted in section 2(b) above, t he state respondent will submit a n implementation plan

for each nonattainment area that will need to include a number of separate and unique

elements

. For example, each implementation plan will need to include a unique RACM/RACT analysis, attainment demonstration, and RFP plan.

However, t here are other activities covered by existing ICRs which complement the elements required in the PM 2.5 SIP

. For example, the existing fine particle monitoring7

network, covered und er a separate, existing ICR, provides essential data for use by states and EPA in identifying key categories of emissions and tracking progress toward attainment.

EPA encourages the states to account for control measures and expected e mission reductions from existing regulations and implementation planning processes

, such as for the

1997 and 2006 PM 2.5 NAAQS, the Ozone NAAQS, the regional haze program, the cross state air pollution rule (CSAPR), the Mercury and Air Toxics Standards. Tak ing such steps, where appropriate, may enable states to reduce the incremental administrative burden

associated with this rule and enable identification of control strategies that achieve multi

pollutant environmental progress at a lower cost.

Relevant IC Rs and their titles are identified below

.

 Requirements for Preparation, Adoption, and Submittal of Implementation Plans

o 51.121

- 51.122 NOx SIP Call...................................2060

- 0445

o 51.160

- 51.166 New Source Review................................2060

- 0003

o 51.321

- 51.323 Air Quality Data Reporting..................2060

- 0088

o 51.353

- 51.354 Inspection/Maintenance......................2060

- 0252

o 51.365

- 51.366 Inspection/Maintenance......................2060

- 0252

 Approval and Promulgation of Implementation Plans

o 52.21 Prevention of Significant Deterioration............... ..2060

- 0003

 Ambient Air Monitoring Reference and Equivalent Methods

o 53.4 .................................................................2080

- 0005

o 53.9(f),(h),(i).......................................................2080

- 0005

o 53.14................................................................2080

- 0005

o 53.15 ...............................................................2080

- 0005

o 53.16(a)

- (d),(f)................................................ .....2080

- 0005

 Outer Continental Shelf Air Regulations

o 55.4

- 55.8 ...........................................................2060

- 0249

o 55.11

- 55.14 ........................................................2060

- 0249

 Ambient Air Quality Surveillance

o 58.11

- 58.14 ........................................................2060

- 0084

o 58.20

- 58.23 ........................................................2060

- 0084

o 58. 25

- 58.28 ........................................................2060

- 0084

o 58.30

- 58.31 ........................................................2060

- 0084

o 58.33 ................................................................2060

- 0084

o 58.35 ................................................................2060

- 0084

o 58.40

- 58.41 .........................................................2060

- 0084

o 58.43 ................................................................2060

- 0084

o 58.45 .................................... ............................2060

- 0084

o 58.50 ................................................................2060

- 0084

 Determining Conformity of Federal Actions to State or Federal Implementation Plans

o 91.150

- 93.160 .....................................................2060

- 0279

 8

- hour Ozone National Ambient Air Quality Standard Implementation Rule

o 2 236.02.............................................................2060

– 05948

3(b) Public Notice Required Prior to ICR Submission to the Office of Management and Budget (OMB)

This is a rule

- related ICR. Comments on this ICR will be requested when the rule is proposed in the Federal Registe r in March 2015.

3(c) Consultations

The EPA is soliciting comment on the proposed PM 2.5 SIP requirements rule and also intends to have a public hearing during the public comment period.

3(d) Effects of Less Frequent Collection

The collections unde r this rule (as reviewed in section 2.b) are necessary to comply with Clean Air Act requirements and provide assurances that identified level s of emission reductions are adequate to ensure timely attainment and maintenance of the PM 2.5 NAAQS

.

3(c) Gener al Guidelines

The reporting and recordkeeping requirements in this proposed rule do not violate any of the regulations promulgated by OMB under 5 CFR part 1320, section 1320.5. T his submission meets the current Paperwork Reduction Act guidelines set fort h by OMB. Those guidelines reflect the requirements of 5 CFR 1320.6. The proposed PM 2.5 NAAQS SIP requirements rule does not require:

 reporting more than once a year;

 respondents to participate in a statistical survey;

 responses to Agency inquiries in less than 30 days;

 respondents to receive remuneration for preparation of reports;

 records to be kept more than 3 years ; 1

 manual methods of reporting.

3(f) Confidentiality

The information requested from the states to fulfill CAA requirements as desc ribed in section 2(b) will rely on emissions levels and control efficiency data provided by certain facilities in the private and public sectors. This information is available from a variety of sources and states should already have information from emissi on sources, as facilities should have provided this information to meet other NAAQS SIP requirements, operating permits, and/or emissions reporting requirements. It is the assimilation and analysis of that data (e.g., for RACM/RACT control measure determin ations, the attainment demonstration, etc.) that is required by this rule.

1 However, the states may choose to retain the information for more than 3 years.9

Emissions and control technology information from emissions sources generally does not reveal the details of production processes. But, to the extent that it may, the affected fa cilities are protected. Specifically, the provision of the emissions and control efficiency information that is confidential, proprietary, and trade secret is protected from disclosure under the requirements of subsections 503(e) and 114(c) of the Clean Ai r Act.

3(g) Sensitive Information

The requested PM 2.5 SIP requirements rule submissions do not include questions whose answers would require sensitive information.



### 4.0 The Respondents and the Information Requested

4(a) Respondents and Nonattainment areas

State and local air agencies 2 are the primary respondents under this ICR. Table 1 lists the 14 areas designated in December 2014 as not meeting the 2012 PM 2.5 NAAQS . These nonattainment area designations will be effective in April 2015, and PM 2.5 Modera te area SIPs will then be due from each relevant state or local air agency in October 2016. Note that

two of the areas are multi

- state nonattainment areas, with part of the nonattainment area located in two contiguous states. A total of 6 states will need to submit PM 2.5 Moderate area SIPs for attaining the 2012 PM 2.5 NAAQS.

Table 1 also includes an estimated 9,000 burden hours for each Moderate area nonattainment plan and an estimated total weighted direct and indirect hourly equivalent salary cost of $ 6 5.10 per hour. ( Section 6 provides more details on these estimates. ) Table 2

describes the estimated incremental burden hours for the initial 2012 PM 2.5 NAAQS nonattainment areas by state and by year.

Table 1. Initial Areas Designated Nonattainment for 2 012 PM 2.5 NAAQS : Estimated

Burden for 2012 PM2

. 5 Moderate SIP Requirements

Initial Nonattainment Area for

2012 PM 2.5 NAAQS State EPA Region 3

- year

Burden

Estimate (Hours) 3

- year

Burden

Estimate ( Dollars)

Allegheny PA 3 9,000 $585,900

Allentown PA 3 9,0 00 $585,900

Canton

- Massillon OH 5 9,000 $585,900

2 Local, state, and federal agencies are part of the North American Industrial Classification System code number 924110 , which includes “admi nistration of air and water resources, and solid waste management programs.” See http://www.census.gov/naics

.10

Initial Nonattainment Area for

2012 PM 2.5 NAAQS State EPA Region 3

- year

Burden

Estimate (Hours) 3

- year

Burden

Estimate ( Dollars)

Cincinnati

- Hamilton KY 4 4,500 $292,950

Cincinnati

- Hamilton OH 5 4,500 $292,950

Cleveland

- Akron

- Lorain OH 5 9,000 $585,900
Delaware County PA 3 9,000 $585,900
Imperial county CA 9 9,000 $585,900

John stown PA 3 9,000 $585,900
Lebanon County PA 3 9,000 $585,900
Los Angeles

- South Coast Air

Basin CA 9 9,000 $585,900

Louisville IN 5 4,500 $292,950

Louisville KY 4 4,500 $292,950

Plumas county CA 9 9,000 $585,900

San Joaquin Valley CA 9 9,000 $585,900

West Silver Valley ID 10 9,000 $585,900

TOTAL 126,000 $8,202,600

Table 2 lists the nonattainment areas and states with remaining SIP submittal or redesignation requirements for the 1997 PM 2.5 NAAQS and the 2006 PM 2.5 NAAQS that potentially c ould be required during the ICR period. For purposes of this draft analysis, it has

been assumed that for the 1997 PM 2.5 NAAQS, a Serious area SIP will be required during the ICR period for one nonattainment area. It also has been assumed that for the 200 6 PM 2.5 NAAQS, a Serious area SIP will be required during the ICR period for seven nonattainment areas. In addition, it has been assumed that redesignation requests will be submitted for seven nonattainment areas for the 2006 PM 2.5 NAAQS. (Note that these assumptions have been made only for the purposes of this analysis, and a number of factors and future state or EPA actions could change the assumptions put forth here.)

Table 2 also includes an estimated 18,000 burden hours for each Serious area

nonattai nment plan, an estimated 300 hours for state development of a redesignation request,

and an estimated total weighted direct and indirect hourly equivalent salary cost of $ 65.10 per hour. Section 6 provides more details on these estimates.11

Table 2

. Rema ining 1997 PM 2.5 and 2006 PM 2.5 Nonattainment Areas with Estimated Burden for SIP Revision or Redesignation Action

Area Name State EPA Reg. Potential Actions during ICR period

5/2015 to 4/2018 Hours for SIP

Revision or Redesignation

Action 3

- yea r Burden

Estimate ( Dollars)

Chico CA 9 2006 PM25

Maintenance Plan 300 $19,530

Fairbanks AK 10 2006 PM25 Serious

Area SIP Revision 18,000 $1,171,800

Imperial County CA 9 2006 PM25 Serious

Area SIP Revision 18,000 $1,171,800

Knoxville

Sevierville

- La

Follette TN 4 2006 PM25

Maintenance Plan 300 $19,530

Liberty

- Clairton PA 3 2006 PM25 Serious

Area SIP Revision 18,000 $1,171,800

Logan ID 10 2006 PM25 Serious

Area SIP Revision 9,000 $585,900

Logan UT 8 2006 PM25 Serious

Area SIP Revision 9,000 $585,900

Nogales, AZ AZ 9 2006 PM25

Maintenance Plan 300 $19,530

Provo UT 8 2006 PM25 Serious

Area SIP Revision 18,000 $1,171,800

Sacramento CA 9 2006 PM25

Maintenance Plan 300 $19,530

Salt Lake City UT 8 2006 PM25 Serious

Area SIP Revision 18,000 $1,171,800

San Francisco Bay Area CA 9 2006 PM25

Maintenance Plan 300 $19,530

San Joaquin Valley CA 9 1997 PM25 Serious

Area SIP Revision 18,000 $1,171,800

San Joaquin Valley CA 9 2006 PM25 Serious

Area SIP Revision 18,000 $1,171,800

West Central

Pinal AZ 9 2006 PM25

Maintenan ce Plan 300 $19,530

TOTAL 145,800 $9,491,58012

4(b) Information Requested

The information requested under this proposed rule, as described in section 2(b) of this ICR, is required to meet the requirements of the CAA. The implemen tation framework set forth in the regulation does not adopt a “one

- size

- fits all” approach to meeting these requirements. This additional flexibility enables the States to customize, to the extent allowed by the Clean Air Act, their approach to attaining and maintaining the PM 2.5 NAAQS.

Data Items. The emissions and control efficiency data required for the attainment demonstration, RFP, RACT, and RACM is assumed to have been collected as a result of reporting activities required by other OMB approved ICR s. For example, the collection of emissions information for many stationary sources is required under other program requirements,

such as the Consolidated Emissions Reporting (CERR) Rule ( see htt p://www.epa.gov/ttn/chief/cerr/index.html ). In developing PM 2.5 SIPs, air agencies are expected to use a range of other readily available data sources, such as existing federal rules that are expected to reduce future emissions of particulate matter precu rsors, and economic and population growth rates.

Respondents’ Activities. The states will compile and reference the data, set forth the analytical methodology, conduct control technology, emission reduction and air quality modeling analyses, develop init ial drafts, hold hearings, adopt rules, regulations, and programs, have discussions with EPA staff as appropriate, refine the draft attainment demonstration as appropriate, adopt the SIP, and formally submit the SIP to the EPA.

Agency Activities. The EPA staff in the regional offices will facilitate timely receipt of the attainment demonstration, RFP, RACT, and RACM requirements by reviewing materials and answering questions from the states regarding regulatory requirements, potential data sources, analyti cal tools, the draft attainment demonstration, and other draft SIP elements. The EPA Regional Offices will evaluate the formal SIP submissions and take rulemaking actions to approve or disapprove the SIP revisions. The EPA headquarters staff will facilitat e policy coordination and national consistency in the timely review and evaluation of plans from states around the country. They will also facilitate information flow among the regions and states to promote the development of acceptable demonstrations and SIP submissions.

Reporting Protocols. The dates for plan submissions and milestone reports are as set forth in subpart 4 of Part D of the CAA (sections 188

- 190), and in the PM 2.5 Implementation rule.



### 5.0 The Information Collected

— Agency Activities, Collecti on Methodology, and Information Management

5(a) States, EPA Regional Offices, and EPA Headquarters Offices

States. The state agencies’ activities include:13

 Develop baseline emissions inventory and projection year inventory.

 Conduct analyses o f economic and technological feasibility of potential control measures and adopt state rules requiring emission reductions to ensure attainment of the standard “as expeditiously as practicable.”

 Develop and evaluate emission reduction strategies, and condu ct air quality modeling showing that existing federal and state emission reduction programs, plus any new emission reduction programs adopted by the state, will result in expeditious

attainment by the attainment date.

 Develop plans to ensure that future em ission reductions will provide for reasonable further progress toward attainment of the standard for the period prior to the area ’ s attainment date

.

EPA Regional Offices. The regional office activities include:

 Respond to inquiries from the air agencie s and providing guidance on SIP development.

 Review technical data, analyses, and draft SIP elements developed by the air agencies.

 Evaluate the formal SIP submissions and conduct rulemaking actions approving or disapproving the SIP submissions.

EPA Hea dquarters. The EPA headquarters office activities include:

 Answer questions regarding application and interpretation of rule provisions.

 Facilitate policy coordination and national consistency in the timely review and evaluation of plans from states aroun d the country.

 Coordinate information flow amongst the regions and states to promote the development of acceptable demonstrations and SIP submissions.

5(b) Collection Methodology and Management

The PM 2.5 SIP submitted by the air agency will set forth the data sources, analytical methods, and the emission reduction and air quality improvement verification procedures used in its development and implementation.

5(c) Small Entity Flexibility

For an approved ICR, the Agency must demonstrate that it has taken all practical steps to develop separate and simplified requirements for small businesses and other small entities. See 5 CFR 1320.6(h). The PM 2.5 NAAQS implementation regulation does not provide a direct administrative burden on small entities.

5(d) Collection Schedule

The SIP deadlines for implementing the PM 2.5 NAAQS under Subparts 4 and 1 were proposed in this rule consistent with CAA requirements. Moderate area SIPs will be due

within 18 months of the effective date of nonattainment area designation. The proposed rule14

requests comment on due dates for certain elements of Serious area SIPs; however, under all proposed options BACM/BACT requirements would be due within 18 months of the date an

area is reclassified as Serio us. Quantitative milestone reports, as required under the CAA, would be due annually.



### 6. Estimating the Burden of the Collection

This section provides information on the hours and costs associated with the information collection for the respondents (the a ffected state and local air agencies) and EPA (regional and headquarters offices). Hours and costs are presented for the activities associated with each collection item for a nonattainment area (or portion thereof) in a given state, as well as the equival ent annual and present value cost estimates.

6(a) Estimating Respondent Burden

The estimated respondent burden represents the estimated staff time associated with the activities required to develop the relevant PM 2.5 SIP or redesignation request and imp lement the plan each year.

The estimated burden in this ICR is incremental to the estimated burden of other EPA environmental reporting obligations. The actual incremental burden is expected to vary across areas for a number of reasons, such as the seve rity of the nonattainment problem and whether existing federal and state emission reduction programs are projected to bring the area into attainment by the 2021 Moderate area attainment date.

Burden E stimate for Initial Nonattainment A reas for the 2012 PM 2.5 NAAQS

Table 1 provides the list of 14 areas initially designated as nonattainment for the PM 2.5 NAAQS in December 2014 and the states responsible for developing the SIP revisions to

meet the standard in December 2021. Table 3 below summarizes th e n umber of

nonattainment SIPs due by state and provides a 3

- year breakdown of expected burden hours by state.

When the 2012 PM NAAQS were revised in December 2012, EPA released a regulatory impact analysis (RIA) at the same time. 3 The purpose of the RIA was to provide the public with illustrative estimates of the potential costs and health and welfare benefits of attaining

the revised annual standard

. The control strategies presented in th e RIA we re illustrative and represent one set of control strategies s t ates might choose to implement in order to meet the

final standards . The RIA analysis developed a base case scenario for the year 2020 that assessed the projected air quality concentrations in 2020 that would be expected with ongoing implementation of a nu mber of national rules, including the following:

3 “Regulatory Impact Analysis for the Final Revisions to the National Ambient Air Quality

Standards fo r Particulate Matter.” U.S. Environmental Protection Agency, Office of Air Quality and Planning Standards, Health and Environmental Impacts Division, February 28, 2013. EPA

452/R

- 12

- 005. See: http://www.epa.gov/ttn/naaqs/standards/pm/s_pm_2007_ria.html

.15

- Light

- Duty Vehicle Tier 2 Rule (1999)

– Heavy Duty Diesel Rule (2000)

– Clean Air Nonroad Diesel Rule (2004)

– Regional Haze Regulations and Guidelines for Best Available Retrofit Technology

Determination s (2005)

– NOx Emission Standard for New Commercial Aircraft Engines (2005)

– Emissions Standards for Locomotives and Marine Compression

- Ignition Engines (2008)

– Control of Emissions for Nonroad Spark Ignition Engines and Equipment (2008)

– C3 Oceangoing Vessels (2010)

– Boiler MACT (2011)

– Hospital/Medical/Infectious Waste Incinerators: New Source Performance Standards and Emission Guidelines: Final Rule Amendments (2009)

– Reciprocating Internal Combustion Engines (RICE) NESHAPs (2010)

– Mercury and Air Toxics Standards (2011)

– Cross

- State Air Pollution Rule (2011)

The RIA analysis projected that all areas expected to be designated as nonattainment for

the 2012 PM 2.5 NAAQS except those areas located in California would be expected to attain

the standar d in 2020

, based only on emission reductions from the federal regulations identified above. Thus, it could be concluded from this analysis that existing federal emission reduction programs will help reduce administrative burden for m any air agencies requir ed to develop SIPs for newly designated nonattainment areas.

As a starting point for developing burden estimates for this analysis , the Agency looked at the total hours expended in related EPA level of effort work assignments for meeting the

1997 ozone NAAQS, exclusive of the air quality modeling. The total estimate for ozone areas classified as Marginal was about 2,000 hours in level of technical effort. 4 The estimated burden for a Subpart 4 PM2.5 SIP revision was considered similar to the burden

for o zone areas classified as Moderate , and estimated at 9,000 hours. The estimated burden

for a Subpart 4 PM2.5 SIP revision after an area was reclassified to Serious was considered

similar to ozone areas with higher classifications and estimated at 18,000 hou rs.

Most of th e estimated burden would be expected to be incurred in the first year because the air agency would be expected to be expending resources developing the PM 2.5 SIPs that would be due 18 months after designation

. For the purposes of this anal ysis, t he ass umed

allocation of total incremental burden across the three years is 50% in year 1, 25% in year 2, and 25% in year 3.

4 EPA Contract No. 68

- D

- 00

- 283; Work Assignments 3

- 53 and 4

- 66.16

Table 3

. Initial Areas Designated Nonattainment for 2012 PM 2.5 NAAQS : Estimated Incremental Burden Hours by State and Y ear

State EPA

Region No. of

Areas or

Parts of

Areas Additional

hours

Year 1 Additional

hours

Year 2 Additional

hours

Year 3

California 9 4 18,000 9,000 9,000

Idaho 10 1 4,500 2,250 2,250

Indiana 5 1 2,250 1,125 1,125
Kentucky 4 2 4,500 2,250 2,250

O hio 5 3 11,250 5,625 5,625
Pennsylvania 3 5 22,500 11,250 11,250

Remaining Subpart 4 Nona ttainment Areas for 1997 and 2006 PM2.5 NAAQS

Table 2 provides the list of areas and states still implementing the 1997 and 2006 PM 2.5 NAAQS requirements that p otentially could be responsible for developing Serious area SIP

revisions or redesignation requests during the ICR period

. For the purpose of this analysis, it is assumed that one of the original 39 nonattainment areas for the 1997 PM2.5 standard (San Joaq uin Valley, CA) will still need to develop a Serious area plan during the ICR period.

Thus

, the bulk of the remaining work for the 1997 nonattainment ar eas consists of developing Maintenance SIPs , and this work was included in the estimates for a prior PM2 5

ICR . The estimated burden hours for development of the remaining Serious area SIP is 18,000 hours.

Of t he 3 2 areas designated as nonattainment for the 2006 PM2.5 standard, Table 2

identifies seven areas that potentially could be reclassified from Mode rate to Serious during the ICR period, and that could have a Serious area SIP (or portions thereof) due within 18 months (also within the period for this ICR). For the purposes of this analysis, t he estimated burden for development of the S IP revision s to address the Serious area requirements is 18,000 hours.

Table 2 also includes 6 nonattainment areas that have attained the 2006 PM25 NAAQS

and have a final Clean Data Determination. ( See

h ttp://www.epa.gov/oar/oaqps/greenbk/rfr2rpt5.html ). The estimated burden hours for development of a redesignation request and maintenance plan is 300 hours. The presumed

allocation of total incremental burden across the three years is 50% in year 1, 25% in year 2, and 25% in year 3.

Using the information in table 2, table 4 below provides a 3

- year breakdown of expected burden hours by state and by year.17

Table 4

. Nonattainment Areas for 1997 and 2006 PM2.5 NAAQS:

Estimated Incremental Burden Hours b y State and Year

State EPA Region Additional

hours Year 1 Additional

hours Year 2 Additional

hours Year 3

AK 10 9,000 4,500 4,500

AZ 9 300 150 150

CA 9 27,450 13,725 13,725

ID 10 4,500 2,250 2,250

PA 3 9,000 4,500 4,500

TN 4 150 75 75

UT 8 22,500 1 1,250 11,250

6(b) Estimating Respondent Cost

Labor costs are estimated for State governments using the total of projected

additional hours for the areas

. These estimates do not reflect staff experience and

eco nomies of scale

. The hourly rates are t he result of estimated directed and indirect cost per employee

. The main source of the information is http://www.opm.gov/oca/payrates/index.htm

The estimated weighted direct salary cost per empl oyee is $35.88 per hour

. This results from a summation of the professional, managerial, and support staff components

.

 Hourly equivalent 2010 Salary of Permanent Professional Staff at GS 11, Step 3 is $33.34

. This is the average of hourly equivalent rate s for the San Francisco, CA and Washington, D.C. areas.

 To account for permanent managerial staff, 1/11 or 9% of the hourly rate for GS 13, Step 3 is added to the professional staff hourly rates

. The average hourly equivalent

rate for GS

- 13 using rates for San Francisco, CA and Washington, D.C. is $47.51

. Nine percent of that is $4.32.

 To account for permanent support staff at GS

- 6, Step 6, 1/8 or 16% of the hourly rate is added to the professional staff hourly rates

. The average hourly equivalent rate for

GS

- 6, Step 6 using rates for San Francisco, CA and Washington, D.C. is $ 22.17

. Sixteen percent of that is $ 3.55

.

The estimated hourly indirect cost per employee is $ 23.90

. This amount is the sum of the following:

 Benefits at 16% of the weighted direct hourly equivalent salary cost per employee or $ 6.59

.

 Sick and annual leave at 10% of the weighted direct hourly equivalent salary cost per employee or $ 4.12

.18

 General overhead at 32% of the weighed direct hourly equivalent salary cost per employee or $ 13.18

.

. The estimated total weighted direct and indirect hourly equivalent salary cost per employee is $ 65.10

. The estimated total incremental respondent burden for the state respondents to meet the new 2012 PM25 SIP requirements and complete the remaining

1 997 and 2006 SIP requirements is provided in Table 5

.

Table 5. Estimated Total Incremental Cost and Hour Burden for the States (Respondents) to Fulfill the new 2012 PM25 SIP requirements and complete the remaining 1997 and 2006 SIP Submittal
Requirement s .

NAAQS Additional Cost

for Year 1 Additional Cost

for Year 2 Additional Cost

for Year 3 Burden for the 3

- year

ICR period (hrs)

2012 $4.1 million $1.8 million $1.7 million 126,000

1997/2006 $4.7 million $2.0 million $1.9 million 145,800

Total $ 8.83 mi llion $ 3.8 million $ 3.6 million 271,800

6(c) Estimating Agency Burden and Cost

The estimated agency burden is derived from the same estimates used for estimating respondent costs in section 6(b). Draft estimates were developed by the headquarters st aff with review by regional office staff and subsequent refinement of the Agency burden and

cost estimates.

The respondent burden was summed by the EPA regional offices and a percentage was applied to the yearly burden estimate to reflect the actions take n on the part of the regional offices. Once yearly burdens were estimated for the Agency’s Regional Offices, a percentage of those amounts are specified to derive estimates for the Agency’s Headquarters Office Burdens. Discussions were held with Regional O ffice and Headquarters staff regarding the percentages and resulting burden estimates.

Agency Regional Office Burden. Table 6 summarizes total incremental respondent burden by Regional Office and provides estimates of total incremental Agency Regional

Off ice burden. The summary of total incremental respondent burden comes from Tables 1 and 2. The Agency Regional Office burden is presumed to be 10% of the estimated total incremental burden for respondent by the EPA Regional Office. The total

incremental bur den allocation for the Agency Regional Offices is 50% in year 1, 25% in year 2, and 25% in year 3.

Agency Headquarters Burden. Table 6 also summarizes total incremental respondent burden Agency headquarter burden. The Regional Office burden estimates fo r years 1, 2,19

and 3 are multiplied by 10% to arrive at an estimate for Headquarters burden for the same 3 years.

Total Incremental Burden for the Agency. The regional and headquarters office burden estimate for year 1 for the 2012 NAAQS is 6,930 hour s. The estimates for years 2 and 3 are 3,460 hours each year. The regional and headquarters office burden estimate for year 1 for the 1997 and 2006 NAAQS is 8,000 hours. The estimates for years 2 and 3 are 4,000 hours each year.

Total Cost for the Agenc y. Using the weighted direct and indirect salary equivalent hour rate derived in section 6(b), the total incremental burden hours are multiplied by that rate. The result is the total cost estimate for the Agency provided in Table 6.

Table 6. Estimated Total Incremental Cost and Hour Burden for the EPA Regions and Headquarter

to Fulfill the new 2012 PM25 SIP requirements and complete the remaining 1997 and 2006 SIP
Submittal Requirements

.

NAAQS Total State

Respondents' burden (hrs) Additional

Cost for Year 1 Additional

Cost for Year 2 Additional

Cost for Year 3 Regions and HQ

Burden for the 3

- year ICR period

2012 126,000 $0.4 million $0.2 million $0.2 million 13,900

1997/2006 145,800 $0.5 million $0.2 million $0.2 million 16,000

Total 271,800 $ 0.9 m illion $ 0.4 million $ 0.4 million 29,900

6(d) Estimating the Respondent Universe and Total Additional Burden and Costs

The total incremental respondent universe burden and cost estimates are presented

in Tables 7 and 8.

Table 7. 2012 PM2.5 NAAQS Tot al Incremental Respondent & Agency Universe Burden and Cost

Estimates

Entity Average Yearly

Burden (hours) 3

- Year

Burden (hrs) Present Value of Costs

for 3

- Year Burden

States 42

, 0 00 126

, 0 00 $7.6 million

Agency 4

, 620 13,860 $0.8 million

Total 46

, 620 13 9,860 $8.4 million20

Table 8. 1997 PM2.5 and 2006 PM2.5 NAAQS Total Incremental Respondent & Agency Universe

Burden and Cost Estimates

Entity Average Yearly

Burden (hours) 3

- Year

Burden (hrs) Present Value of

Costs for 3

- Year

Burden

States 48,600 14 5,800 $8.8 million

Agency 5,346 16,038 $0.96 million

Total 53,946 161,838 $9.7 million

* The estimates are in current year (20 12 ) dollars. Costs for years 2 and 3 are calculated using the equation Present Value = Future Value/ (1 + interest rate) t ,wh ere “t” is the number of years hence (i.e., 0 for year 1, 1 for year 2, 2 for year 3). The adjusted values for years 1, 2, and 3 are then summed.

6(e) Reason for Change in Burden

We are requesting an increase in burden of 3 02

, 0 00 hours due to implemen tation of this new regulation and the implementation of the remaining requirements for the 1997 PM25 and 2006 PM25 NAAQS

. This burden estimate is lower than the estimate for the previous PM2.5 Implementation ICR renewal primarily because the number of des ignated nonattainment areas covered by this ICR is lower. The estimates have been calculated using 2012 dollars and some assumptions regarding overhead, O&M costs, and capital costs have been adjusted to meet

current guidelines and common procedures for p reparing ICRs.

6( f ) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information for the 2012 PM25 NAAQS is estimated to average 2,625 hours per state respondent for this reporting period. This estimate is der ived by taking 42,000 hours, the average yearly burden for the states identified in Table 1, and dividing by 16, the number of affected state responses. Similarly, the annual public reporting and recordkeeping burden for this collection of

information for the 1997 and 2006 NAAQS is estimated to average 3,240 hours, which is the 48,600 hours average yearly burden for the states identified in Table 1, and dividing by 15, the number of affected state responses.

Burden means the total time, effort, or financi al resources expended by persons to generate, maintain, retain, disclose, or provide information or for a Federal agency other than the

EPA to do so

. This estimate includes the time and burden needed to c onduct the tasks associated

each state submitting t he PM 2.5 SIP required for each PM 2.5 nonattainment area

. The PM 2.5 SIP s due during this ICR reporting period will need to include several elements, including the attainment demonstration, RFP plan , RACT and RACM

. In meeting these milestones

, such

increment al efforts may include reviewing instructions as well as verifying, processing, maintaining, and disclosing information

. Such efforts may require incremental development, acquisition, installation, and/or utilization of technological systems for several pu rposes

. These21

purposes include collecting, verifying, validating, processing, maintaining and disclosing

information associated with the each milestone

. The incremental efforts may result from adjusting the ways to comply with the previously applicable ins tructions associated with other National Ambient Air Quality Standard s such as 8

- hr ozone and PM 10

. Consequently, in meeting the milestones, there could be some incremental burden associated with learning/training, searching data sources, and transmitting the deliverables.

An A gency may not conduct or sponsor, and a person is not required to respond to a collection of information unless it displays a currently valid OMB control number

. The OMB

control numbers for the EPA ’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15

. When this ICR is approved by OMB, the Agency will publish a technical amendment to 40 CFR part 9 in the Federal Register to display the OMB control number for the approved information collection requirements contained in the final implementation rule

. However , as was stated in the April 2007 Federal Register Notice for the PM 2.5 Implementation Rule , “.. the failure to have an approved ICR for this rule does not affect the statutory obligation for the state s to submit SIPs as required under part D of the CAA.”

The Agency established a docket for the PM 2.5 National Ambient Air Quality Standard s State Implementation Requirements Rule under Docket ID No.OAR

- 20 13

- 0 691

. All documents in the

docket are listed in the EDOCKET index at http://www.epa.gov/epahome/dockets.htm or http://www.regulations.gov

. Altho ugh listed in the index, some information such as Confidential

Business Informat ion is not publicly available

. Other information such as copyrighted materials are not placed on the internet, but are available in hard copy form at the EPA Docket Center (Air Docket), EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC

. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays

. The telephone number for the Public Reading Room is (202) 566

- 1744

. The telephone number for the Office of Air and Radiation Docket and Inform ation Center is (202)

566

- 1742

.